UMN Guidance: Foreign Influence
Memorandum: New NIH Guidance on Foreign and Domestic Activities (9/13/19) from Vice President for Research Christopher J. Cramer and Associate Vice President for Research Pamela Webb to NIH investigators regarding the need to report foreign and domestic activities related to their research. See our summary of NIH Guide Notice NOT-OD-19-114 requirements below.
Memorandum: Reporting/Compliance Obligations regarding Foreign Institutions and Scholars (12/20/18) from University of Minnesota President Eric W. Kaler, Executive Vice President and Provost Karen Hansen, and Vice President for Research Christopher J. Cramer detailing guidance for the reporting and compliance obligations when engaging with Foreign Institutions & Scholars.
UMN Summary of NIH Guide Notice
Other Support: Expanded List of Reportable Items
The updated definition includes “all resources made available to a researcher in support of and/or related to all of their research endeavors, regardless of whether they have monetary value and regardless of whether they are based at the institution the researcher identifies for the current grant.” Examples of items that require reporting include:
- all external research support from any source and regardless of whether the support is administered through the University of Minnesota or elsewhere, or by the investigator him/herself;
- institutional research grants that include measurable effort;
- investigator participation in foreign talent programs;
- external financial support for laboratory personnel;
- provision of high-value materials that are not freely available;
- paid or unpaid teaching or other summer appointments that are “in support or and/or related to research efforts.”
In their FAQs, NIH indicates that foreign collaborations that “directly benefit” an investigator’s research must be reported even if our investigators are not involved and the project is not funded with NIH dollars. Gifts, training grants, and prizes continue to be excluded from reporting.
Other Support: No Change in Who Needs to Report
Other support is required for the PI/PD and others identified by the PI/PD in the proposal or RPPR as Senior/Key Personnel. A definition of Senior/Key personnel is included in the Guide Notice for convenience.
Foreign Component: Slightly Expanded Definition
This section is mostly the same but the prior approval requirement to designate a foreign component of a grant would be triggered if a separately-funded collaborator outside of the US performs experiments in support of the PI/PD’s project – even if no NIH funding is involved. In addition, if a foreign visiting scientist or postdoc working on an NIH grant is planning to leave the investigator’s US lab but returns to their home country and will continue work on the project, please consult with SPA. NIH is currently considering whether the portion of the work done in a foreign location constitutes a “foreign component” that will need prior approval.
Other Support/Biosketch: Appointment Listing Refinements
The biosketch appointment definitions have been slightly updated to include “all positions and scientific appointments held by senior/key personnel that are relevant to an application … includes titled academic, professional, or institutional appointments whether or not remuneration is received, and whether full-time, part-time or voluntary (including adjunct, visiting or honorary).” This includes paid and unpaid appointments at foreign institutions that do not involve explicit time commitments.
NIH is working to update its “Other Support” forms to make them easier to use for the types of data being requested, but for the moment, investigators should simply provide the requested data elements (as applicable) in a format that meets or is close to the “Other Support” instructions. NIH is aware that there are some wording variances between their Grants Policy Statement and application forms/instructions and is working to harmonize these to add additional clarity.